Reference is made to our previous circulars regarding the developments and sanctions imposed on Russia due to the escalation of the conflict in Ukraine. On the basis of recent advice received from our correspondents, we would like to inform our Members as follows:
- The state of emergency in Ukraine has been extended until April 25, 2022. All ports under Ukrainian control are closed. Recent circulars issued by IMO indicate that a number of foreign-flagged ships are currently unable to leave Ukrainian ports due to the situation in the Black Sea.
- The Ukrainian ports of Kherson and Berdyansk are occupied by Russian troops. No shipping traffic is possible in these ports.
- The port of Mariupol is currently being bombarded daily by Russian artillery. The port and the Sea of Azov are blocked by the Russian navy.
- A ban has been imposed on Ukrainian men (aged 18-60 years) from leaving the country without required authorization. We understand that it is currently not possible to recruit Ukrainian crew members from Ukraine.
- Difficulties are currently being reported in connection with the repatriation of Ukrainian crew members. The airports of Odessa and Kiev are closed, repatriation of Ukrainian crew members is mainly carried out via the nearest airports in Romania (Bucharest) and Poland (Warsaw). From there, crew members may travel to Ukraine by domestic transport.
- In Russian ports, Ukrainian crewmembers may still in some cases be interviewed by Russian immigration authorities and may be asked about their attitude towards the conflict in Ukraine and/or be refused entry to the port. We advise our Members to alert their Ukrainian crew members and recommend them to answer these questions in a neutral fashion.
- We have received reports that in Swedish ports and a number of ports in the United Kingdom, stevedores have refused to serve ships going to and from Russia, ships carrying Russian import and export cargo and ships with the Russian flag.
Members are reminded that assistance and/or advice from the NNPC does not in any way replace or form part of the member’s own due diligence obligation to perform sanction checks. Sanction checks should be performed on all parties and cargoes and a specialist should be consulted whenever necessary. It is also important to note that even if no sanctions apply to a cargo, this does not guarantee that there will not be restrictions imposed by banks and/or authorities. Members should also be aware of possible practical issues related to shipments to and from Russia, such as refusal of services by stevedores or bunker suppliers.